Laserfiche WebLink
PLAN PROPONENT'S MOTION FOR RELIEF FROM FEDERAL RULE OF <br />BANKRUPTCY PROCEDURE 2002(b) PURSUANT TO FEDERAL RULE OF <br />BANKRUPCY PROCEDURE 9006 (b) AND/OR (c) <br />Recreation Properties, Ltd. ("RPL") proponent of the Plan of Reorganization Dated May <br />8, 2020, by and through its counsel Miller & Law, P.C., respectfully moves, pursuant to Federal <br />Rule of Bankruptcy Procedure 9006 (b) and (c) for relief from Federal Rule of Bankruptcy Rule <br />2002(b). In support of this Motion, RPL states as follows: <br />CERTIFICATE OF CONFERAL <br />The undersigned has conferred with the Chapter 11 Trustee and the United States Trustee <br />regarding the relief requested herein. Neither party opposes the relief requested herein. <br />BACKGROUND <br />1. This case was commenced as an Involuntary Chapter 7 initiated by creditors. The <br />Order for Relief was entered on January 24, 2017. David Lewis ("Trustee") was duly appointed <br />as the Chapter 7 Trustee in this case. <br />2. The Debtor confessed the involuntary petition and did not attempt to convert this <br />case to a case under Chapter 11. The Debtor's pre-petition management team consisted of two <br />individuals, Stephen Guyer and Lee Rice. Mr. Rice passed away shortly before the <br />commencement of this case. Mr. Guyer attended the first meeting of creditors and has generally <br />cooperated with the Trustee but has not otherwise participated in this case. <br />3. This case was converted to a Chapter 11 case by the Court's order of February 1, <br />2019 and John C. Smiley was appointed as Chapter 11 Trustee. <br />4. RPL is the proponent of a Plan of Reorganization Dated May 8, 2020 (the "Plan") <br />and filed a Disclosure Statement also dated May 8, 2020 (the "Disclosure Statement"). <br />5. By Order dated August 13, 2020, the Court set a hearing on the adequacy of the <br />Disclosure Statement for September 23, 2020 and set a deadline for objection to the Disclosure <br />Statement for September 16, 2020. Additionally, through that Order, the Court required RPL to <br />UNITED STATES BANKRUPTCY COURT <br />SEP Q 9 20ZQ <br />FOR THE DISTRICT OF COLORADO <br />N <br />IN RE: ) <br />D1VISIN NG A D SAFETY <br />� <br />COLORADO GOLDFIELDS, INC., ) CASE NO. <br />16 -20910 -MER <br />a Delaware Corporation, ) CHAPTER: <br />7 <br />Debtor. ) <br />PLAN PROPONENT'S MOTION FOR RELIEF FROM FEDERAL RULE OF <br />BANKRUPTCY PROCEDURE 2002(b) PURSUANT TO FEDERAL RULE OF <br />BANKRUPCY PROCEDURE 9006 (b) AND/OR (c) <br />Recreation Properties, Ltd. ("RPL") proponent of the Plan of Reorganization Dated May <br />8, 2020, by and through its counsel Miller & Law, P.C., respectfully moves, pursuant to Federal <br />Rule of Bankruptcy Procedure 9006 (b) and (c) for relief from Federal Rule of Bankruptcy Rule <br />2002(b). In support of this Motion, RPL states as follows: <br />CERTIFICATE OF CONFERAL <br />The undersigned has conferred with the Chapter 11 Trustee and the United States Trustee <br />regarding the relief requested herein. Neither party opposes the relief requested herein. <br />BACKGROUND <br />1. This case was commenced as an Involuntary Chapter 7 initiated by creditors. The <br />Order for Relief was entered on January 24, 2017. David Lewis ("Trustee") was duly appointed <br />as the Chapter 7 Trustee in this case. <br />2. The Debtor confessed the involuntary petition and did not attempt to convert this <br />case to a case under Chapter 11. The Debtor's pre-petition management team consisted of two <br />individuals, Stephen Guyer and Lee Rice. Mr. Rice passed away shortly before the <br />commencement of this case. Mr. Guyer attended the first meeting of creditors and has generally <br />cooperated with the Trustee but has not otherwise participated in this case. <br />3. This case was converted to a Chapter 11 case by the Court's order of February 1, <br />2019 and John C. Smiley was appointed as Chapter 11 Trustee. <br />4. RPL is the proponent of a Plan of Reorganization Dated May 8, 2020 (the "Plan") <br />and filed a Disclosure Statement also dated May 8, 2020 (the "Disclosure Statement"). <br />5. By Order dated August 13, 2020, the Court set a hearing on the adequacy of the <br />Disclosure Statement for September 23, 2020 and set a deadline for objection to the Disclosure <br />Statement for September 16, 2020. Additionally, through that Order, the Court required RPL to <br />